According to Rule 133 Section 3 Extrajudicial confession, not sufficient ground for conviction. — An extrajudicial confession made by an accused, shall not be sufficient ground for conviction, unless corroborated by evidence of corpus delicti. (3)

Mali yung pag apply ng doctrines on corpus delicti especially when the Supreme Court in affirming the validity of charges against De Lima held na hindi kelangan ng corpus delicti of the drugs to be trafficked